The following excerpt is from Pub. Watchdogs v. S. Cal. Edison Co., Case No.: 19-CV-1635 JLS (MSB) (S.D. Cal. 2019):
Under California law, "a private individual . . . does not have a cause of action on account of a public nuisance unless he alleges facts showing special injury to himself in person or property of a character different in kind from that suffered by the general public." Brown v. Petrolane, Inc., 102 Cal. App. 3d 720, 725 (1980) (emphasis in original) (collecting cases). "Under this rule[,] the requirement is that the plaintiff's damage be different in kind, rather than in degree, from that shared by the general public." Id. (collecting cases).
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